`
`
`1526 Gilpin Avenue
`Wilmington, Delaware 19806
`United States of America
`Tel: 302-449-9010
`Fax: 302-353-4251
`www.devlinlawfirm.com
`
`
`
`
`
`April 1, 2024
`
`
`
`VIA CM/ECF
`
`The Honorable Christopher J. Burke
`J. Caleb Boggs Federal Building
`844 N. King Street
`Unit 28, Room 2325
`Wilmington, DE 19801-3555
`
`
`
`
`Dear Judge Burke,
`
`
`Re: Midwest Energy Emissions Corp., et. al v. Arthur J. Gallagher & Co.,
`
`et al., C.A. No. 19-1334-CJB
`
`Pursuant to the Court’s March 8, 2024 oral order, post-trial motions are due on
`April 5, 2024. The parties have conferred regarding the appropriate timing of ME2C’s
`post-trial motions given the upcoming bench trial on Defendants’ equitable defenses.
`The parties agree that the issues in those motions may be most efficiently presented after
`that bench trial is completed. This would not affect the deadline for Defendants’ post-
`trial motions.
`
`
`Accordingly, Plaintiffs request that the Court order that ME2C’s post-trial
`motions (i.e., motions for willfulness enhancement, attorneys’ fees, and/or interest) may
`be filed after the bench trial on Defendants’ equitable defenses. Defendants do not
`oppose this request.
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully,
`
`
`
`
`
` James M. Lennon
`
`
`
`
`
`
`
`James M. Lennon (No. 4570)
`
`
`
`
`
`
`
`JML/dla
`cc:
`Clerk of the Court (via CM/ECF)
`
`Counsel of Record (via CM/ECF)
`
`
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